Williams v. Sun Life Ansurance Co. of Canada

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA

August 20, 2010

LAURA WILLIAMS, PLAINTIFF,v.SUN LIFE ASSURANCE COMPANY OF CANADA, SUN LIFE FINANCIAL, COMMUNITY HOSPITALS OF CENTRAL CALIFORNIA DBA COMMUNITY MEDICAL CENTERS EMPLOYEE BENEFIT PLAN AND DOES 1-10 DEFENDANTS.

APPLICATION FOR ORDER FOR ADDITIONAL TIME TO FILE JOINT NOTICE OF INTENT TO PROCEED

Plaintiff, LAURA WILLIAMS, through her attorney, Steven M. McQuillan of Jacobson, Hansen, Najarian & McQuillan, respectfully submits that the parties request an additional 45 days to file a Further Joint Notice of Intent to Proceed.

Defendants counsel of record, Eric Mathiesen, has indicated to Plaintiff's counsel that Defendants hereby consent to this extension of time and have no objections, 22 however a stipulation cannot be reasonably obtained as Mr. Mathiesen is out of town and 23 unable to receive documents and endorse a stipulation for extension of time.

Accordingly, the parties respectfully request an order to extend the time to file a Joint Notice of Intent to Proceed to October 7, 2010.

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